RESPONDENT FAILED TO PREPARE AND KEEP RECORDS OF SOME QUARTERLY VISUAL INSPECTIONS FOR ITS PCB TRANSFORMER (WHICH CONTAINS PCBS AT A CONCENTRATION OF (GREATER THAN 500,000 PPM)FROM 2008-2010 AND INCORRECTLY MARKED THAT TRANSFORMER AS A PCB-CONTAMINATED TRANSFORMER (WHICH BY DEFINITION CONTAINS PCBS A CONCENTRATIONS LESS THAN 50 PPM), IN VIOLATION OF 40 C.F.R. SECTIONS 761.30(a)(1)(ix) AND (xii) AND 761.40 RESPECTIVELY.